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Land Use Policy 22 (2005) 103–114 Policy impact on desertification: stakeholders’ perceptions in southeast Spain Juan J. On˜ate*, Begon˜a Peco Department of Ecology, Universidad Aut ! onoma de Madrid, 28049-Madrid, Spain Received 10 March 2003; received in revised form 9 January 2004; accepted 14 January 2004 Abstract Two related land use change dynamics characterise the Guadalent ! ın basin (southeast Spain) as one of the most severe cases of desertification in Europe: (1) expansion of highly productive irrigated agriculture in the valley, and (2) intense contemporary changes in the surrounding impoverished dry lands. On the basis of documented information, we trace the effects of past policies on these dynamics, illustrating such role with the results of 25 in-depth interviews on the issue with relevant stakeholders in the area. In line with relevant related research in other parts of the Mediterranean, our conclusion is that implemented policies have overemphasised the economic dimensions of development at the expense of environmental sustainability, specifically targeted policy instruments having failed to address the issue of desertification. Given this experience, it is estimated that only strict environmental policy enforcement together with people education could bring the situation under control. r 2004 Elsevier Ltd. All rights reserved. Keywords: Desertification; Policy impacts; Stakeholders; Agriculture; Irrigation; Spain Introduction Desertification is a complex process of land degrada- tion reducing land productivity and the value of natural resources because of adverse human actions and climatic variations. Identified as a global problem in the 1970s (UNCOD, 1977), the need to combat desertification was also quickly recognised in Mediterranean countries (i.e. Portugal, Spain, Italy and Greece) of the European Union (EU) (Fantechi and Margaris, 1986; UNCCD, 1994). Great efforts have been made by the EU to under- stand the physical processes involved in desertification at a pan-Mediterranean scale (see review in Geeson et al., 2002) and the contributing socio-economic factors (Fantechi et al., 1995; CEC, 1997). To date, however, land use scenarios have often used top-down rational- isations of the process, assuming that once a policy is formulated it automatically has a beneficial outcome on the ground. This has neglected the necessary integration of perceptions, decision-making and varied responses to policies by actors ‘on the ground’ (Lemon and Seaton, 1999), often leading to an incomplete understanding of why many national and EU policies have failed to rectify, and in some cases even exacerbated, desertifica- tion processes. We focus here on the society-driven aspects of the problem (van der Leeuw, 1998), under the assumption that the development of regional and local scenarios and feasible strategies and policy options to fight desertifica- tion can only be approached through the comprehension of the context within which individual decisions are made. The consideration of the perceived nature of the problem and effects of past policies by the major stakeholders in the policy arena is our first step towards these objectives. This paper reconstructs the effects of past policies on desertification in the Guadalent ! ın basin (southeast Spain) on the basis of documented information and the discourses of interviewed selected stakeholders at the national, regional and local levels. Methodological issues Study area The Guadalent ! ın area covers 3300 km 2 in the south- east of the Iberian Peninsula and encompasses the whole ARTICLE IN PRESS *Corresponding author. Fax: +34-91-3978001. E-mail address: [email protected] (J.J. On˜ate). 0264-8377/$ - see front matter r 2004 Elsevier Ltd. All rights reserved. doi:10.1016/j.landusepol.2004.01.002
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Policy impact on desertification: stakeholders’ perceptions in southeast Spain

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Page 1: Policy impact on desertification: stakeholders’ perceptions in southeast Spain

Land Use Policy 22 (2005) 103–114

ARTICLE IN PRESS

*Correspondi

E-mail addre

0264-8377/$ - see

doi:10.1016/j.lan

Policy impact on desertification:stakeholders’ perceptions in southeast Spain

Juan J. Onate*, Begona Peco

Department of Ecology, Universidad Aut !onoma de Madrid, 28049-Madrid, Spain

Received 10 March 2003; received in revised form 9 January 2004; accepted 14 January 2004

Abstract

Two related land use change dynamics characterise the Guadalent!ın basin (southeast Spain) as one of the most severe cases of

desertification in Europe: (1) expansion of highly productive irrigated agriculture in the valley, and (2) intense contemporary

changes in the surrounding impoverished dry lands. On the basis of documented information, we trace the effects of past policies on

these dynamics, illustrating such role with the results of 25 in-depth interviews on the issue with relevant stakeholders in the area. In

line with relevant related research in other parts of the Mediterranean, our conclusion is that implemented policies have

overemphasised the economic dimensions of development at the expense of environmental sustainability, specifically targeted policy

instruments having failed to address the issue of desertification. Given this experience, it is estimated that only strict environmental

policy enforcement together with people education could bring the situation under control.

r 2004 Elsevier Ltd. All rights reserved.

Keywords: Desertification; Policy impacts; Stakeholders; Agriculture; Irrigation; Spain

Introduction

Desertification is a complex process of land degrada-tion reducing land productivity and the value of naturalresources because of adverse human actions and climaticvariations. Identified as a global problem in the 1970s(UNCOD, 1977), the need to combat desertification wasalso quickly recognised in Mediterranean countries (i.e.Portugal, Spain, Italy and Greece) of the EuropeanUnion (EU) (Fantechi and Margaris, 1986; UNCCD,1994).Great efforts have been made by the EU to under-

stand the physical processes involved in desertificationat a pan-Mediterranean scale (see review in Geeson et al.,2002) and the contributing socio-economic factors(Fantechi et al., 1995; CEC, 1997). To date, however,land use scenarios have often used top-down rational-isations of the process, assuming that once a policy isformulated it automatically has a beneficial outcome onthe ground. This has neglected the necessary integrationof perceptions, decision-making and varied responses topolicies by actors ‘on the ground’ (Lemon and Seaton,1999), often leading to an incomplete understanding of

ng author. Fax: +34-91-3978001.

ss: [email protected] (J.J. Onate).

front matter r 2004 Elsevier Ltd. All rights reserved.

dusepol.2004.01.002

why many national and EU policies have failed torectify, and in some cases even exacerbated, desertifica-tion processes.We focus here on the society-driven aspects of the

problem (van der Leeuw, 1998), under the assumptionthat the development of regional and local scenarios andfeasible strategies and policy options to fight desertifica-tion can only be approached through the comprehensionof the context within which individual decisions aremade. The consideration of the perceived nature of theproblem and effects of past policies by the majorstakeholders in the policy arena is our first step towardsthese objectives.This paper reconstructs the effects of past policies on

desertification in the Guadalent!ın basin (southeastSpain) on the basis of documented information andthe discourses of interviewed selected stakeholders at thenational, regional and local levels.

Methodological issues

Study area

The Guadalent!ın area covers 3300 km2 in the south-east of the Iberian Peninsula and encompasses the whole

Page 2: Policy impact on desertification: stakeholders’ perceptions in southeast Spain

ARTICLE IN PRESS

Andalucía

Castilla LaMancha

Comunidad Valenciana

Región de Murcia

Madrid

0 km

N

Lorca331

Guadalentín

879

4941822

1103

1100

1585

42

Totana255

489

River

Alhama176

1501

Andalucía

Castilla LaMancha

Comunidad Valenciana

Región de Murcia

Madrid

km0 20km

NN

Lorca331

Guadalentín

879

4941822

1103

1100

1585

42

Totana255

489

River

Alhama176

1501

Lorca331

Guadalentín

879

4941822

1103

1100

1585

42

Totana255

489

River

Alhama176

1501

Fig. 1. Location of Guadalent!ın basin. Main cities and altitudes

(metres above sea level) are given for reference.

50

100

150

200

250

1960 1965 1970 1975 1980 1985 1990 1995 2000

Irri

gate

d su

rfac

e (t

hous

and

ha)

Fig. 2. Regional trends in irrigated land up to the present 191,100 ha

(Source: CEH, 2001).

J.J. Onate, B. Peco / Land Use Policy 22 (2005) 103–114104

basin of the Guadalent!ın River, a tributary of the SeguraRiver. Administratively, most of the area is in theMurcia region with a minor part in Andaluc!ıa (Fig. 1).Two main dimensions characterise the Guadalent!ın as

one of the most severe cases of desertification in thenorthern Mediterranean: (1) surface and groundwateroverexploitation (CHS, 2001), soil salinisation (Velaet al., 2002) and natural habitat destruction (Mart!ınezand Esteve, 2000) along with a massive increase ofirrigation agriculture in the valley in recent decades tothe present 48,000 ha (CEH, 2001); and (2) intenseerosive dynamics in the hilly dry land zones, rooted inhistorical land use changes acting on a sensitivecombination of semi-arid climate and vulnerable soils(see details in L !opez-Berm !udez et al., 1997). The spreadof irrigated land is part of a regional trend (Fig. 2), nowalmost 31% of the regional Utilised Agricultural Area,more than two-fold the national level (MAPA, 2001).Horticulture production and related activities havedriven a process of remarkable economic development,1

which has been the focus of resources and attention at

1 In the 1975–1996 period, the primary sector in the region grew at a

rate of 4.3%, while the growth of the entire regional economy was only

2.98% (MINHAC, 2000). As a result, in 1999 the share of the primary

sector in the Regional Gross Added Value was 8.9%, double the

national figure of 4.2% (INE, 2000).

the expense of marginalised dry lands, adding importantsocial dimensions to the desertification issue in the area.

Rationale of the study

Our point of departure is that desertification problemsin the Guadalent!ın are rooted in certain physicalcircumstances—a semi-arid climate, available ground-water and highly erodable metamorphic and sedimen-tary rock—in which historical trends of land use, socialand technological change have developed. Developmentpaths before and after EU accession in 1986 haveexacerbated two related land use change dynamics,considered proximate causes of desertification: expan-sion of irrigated agriculture in the valley, and intensechanges in the surrounding dry land areas. The former isa main driver for aquifer depletion in semi-arid climates,leading potentially to both boreholes drying up andaquifer salinisation, in a similar equation to that faced inthe Greek Argolid valley (Lemon et al., 1994). The latterinclude both intensification and abandonment of agri-cultural practices as well as sudden changes in cropchoices following the more rewarding EU subsidies,which effects on erosion rates have also been reportedelsewhere in the Mediterranean (Kosmas et al., 1997).On the basis of documented information and our own

work (Cummings et al., 2001), our first interest was toreconstruct the role of past policies in these processes,considering as well the perception of such effects bystakeholders relevant to the issue (see next section). Inparticular, the role of a set of recent instruments whichcould have tackled the problem, such as agri-environ-mental and agri-forestry schemes, hydrological correc-tive measures and forestry measures and land useplanning policies, was investigated.

In-depth interviews

In order to contrast and illustrate the rationale ofour approach, the perception by selected stakeholders in

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Table 1

Thematic areas and categories used to classify the stakeholders’

discourse

Thematic area Category

Background Perceptions of desertification

Historical trends in land use change in

the area

Contemporary land

use changes and

ultimate effects—the

policy impacts

Irrigation expansion and related

processes

Changes in dry land and related

processes

Effects on desertification

Role of recent policy

instruments

Agri-environmental and agri-forestry

schemes

Hydrological corrective measures and

forestry measures

Land use planning and related policies

Source: Authors.

2Having formerly belonged to the Ministry of Public Works, in 1996

water authorities were transferred to the newly created Ministry of

Environment, a change with no visible effects on the overall approach

to water management in Spain.

J.J. Onate, B. Peco / Land Use Policy 22 (2005) 103–114 105

regard to both the nature of the problem and the effectsof past policies on desertification was acquired by meansof face-to-face semi-structured and taped interviews.Pursuing the development of an holistic view of the

issue, an appreciation of the variety of perspectives wasconsidered essential (Lemon, 1999). Twenty-five rele-vant stakeholders were selected, including governmentalrepresentatives at the national (six interviewees) andregional (7) levels, farmers’ organisations (6), academics(4), private corporations (1) and non-governmentalorganisations (1). Appendix A shows coding andaffiliation of interviewed stakeholders. Existing contactsat the governmental levels acted as ‘sponsors’, facili-tating access to most administrative officials, some ofwho in turn suggested ‘snowballing’ contacts (Lemon,1999) from farmers’ organisations and private corpora-tions. We directly contacted the remaining interviewees.The interviews were roughly organised around

thematic areas and categories (Table 1), reflecting therationale of our approach. A semi-structured approach(Lemon, 1999) was adopted, combining closed questionsfor the analysis of, e.g., the perceptions of desertifica-tion, and the flexibility of more open questions targetedat capturing the stakeholders’ discourse in regard to theeffects of past policies on desertification. In order toreinforce the discursive nature of our paper, particularlyemphatic quotations from interviews have been includedin the text, balancing their number among intervieweesfor the sake of objectivity.

Structure of the paper

We have structured the paper in six main sections.Firstly, we shall describe the context in which thenetwork of interviewed stakeholders is inserted, neededto understand the power structure and politics among

them. Secondly, an analysis of stakeholders’ perceptionof desertification is dealt with, useful to provide acontext for the interviewees’ discourse on our approach.The next two sections focus on the reconstruction of theorigins (historical trends) and contemporary reality(policy choices and resulting processes) of land usechange dynamics. The role of the recent policy instru-ments that could have tackled the problem is thenexplored in section five. Finally, the main conclusions ofthe research and the prospects for future action aresummarised.

Power structure and politics of the network of interviewed

stakeholders

Relationships between interviewed stakeholders seemto be primarily a function of both the power structureprevailing amongst the representatives of the adminis-tration and the historical and present status of theirrigation issue in the region.The 1978 Spanish Constitution decentralised govern-

ment, sharing power between the central (hereafter‘Nation’) and the regional governments or Comunidades

Aut !onomas (hereafter ‘Regions’). Since 1982 the Regionof Murcia has become responsible for the legislativedevelopment and implementation of several aspectscovered by this paper (Table 2).In agriculture, the National role is now limited to

liasing between the EU Regulations and Regionalperformance and co-ordinating inter-regional initiatives.Real power lies thus with the regional AgricultureDepartments.The Nation does, however, still have considerable

power over water resources through the River Boards,which under the 1985 Water Act must design theirrespective Hydrological Plans, administrate and controlpublic water resources, uses and the infrastructurefinanced by them.2 The Confederaci !on Hidrogr !afica del

Segura (CHS) is responsible for the 18,815-km2 SeguraRiver basin, including the Guadalent!ın sub-basin.Under the Franco dictatorship, the Ministry of

Agriculture, promoting land use transformation, andthe CHS, regulating and supplying water resources,failed in overcoming, with the development of infra-structure plans, the historical ineffectiveness in con-solidating and guarantying existing irrigation (CHS,2001). The ‘irrigation problem’ had therefore alreadyarisen well before the establishment of the RegionalGovernment. From the point of view of nationalrepresentatives (i.e. interview respondents 5.NAd1,

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Table 2

Year of transfer from national ministries and issues under the Murcia

regional administration

Year Matter

1982 Promotion of regional economic development

under national policy objectives

Agriculture and rural development

1983 Physical planning and public works of

Regional interest

1984 Management of the environment

1985 Project, construction and exploitation of

hydraulic infrastructures

Water supply and sewerage

Management of nature conservation

Source: Own compilation.

J.J. Onate, B. Peco / Land Use Policy 22 (2005) 103–114106

6.NAd2, 7.NAd3, 8.NAd4, 9.NAd5 and 10.NAd6),regional authorities have just worsened the problemsince they took over responsibility for the matter.Regional authorities, on the contrary, argue that theproblem was a legacy they are trying to resolve.Nonetheless, respondents 12.RAd2 and 16.RAd6, bothnational administration civil servants ‘‘transferred’’ tothe regional level, have confirmed that autonomousfunctioning has been considerably worse than theprevious centralistic one, pointing to lack of experience,the political direction of the leaders, proximity to thevoter and shortage of means and financial resources, asthe main reasons. No additional justification of theseclaims has been found in published literature.In spite of the CHS being classified as ‘national

administration’, the rest of stakeholders, includingacademics, still consider it responsible for the ‘irrigationproblem’ claiming that the CHS has abandonedresponsibility on issues such as groundwater control orwater quality. The CHS representatives in turn, assertthat regional administration has kept on promotingirrigation and encouraging farmers’ demands for water,while not having controlled industrial and urbansewage. Besides, the CHS officials themselves also arguethat rigid implementation of the law provisions on watercontrol has been unaffordable due to the poor economicand human resources available to the CHS.Irrigation as a major regional interest is now

unanimously supported by the entire regional adminis-tration and, although recognising the negative effects ofits uncontrolled increase on their respective issues ofcompetence, both environment and physical planningdepartments act as subsidiary to this objective, claiminglack of effective powers to tackle the problem.All interviewed stakeholders expressed their opinions

under the expectations raised by the recently enactedNational Hydrological Plan (NHP), which foresees a

huge investment in infrastructure for water transferfrom the Ebro River basin (northeast Spain) to Murciaand neighbouring regions (MIMAM, 2001a). In the faceof heated debate and protests at the national level (Saur!ıand Del Moral, 2001), expectations of new watersupplies have spurred most of Murcia society to supportthe NHP, to the point where critics such as envi-ronmentalist groups and a few academics are branded as‘traitors’ of regional interests. Also largely debated, aNational Irrigation Plan, scenario 2008, was passed inApril 2002, foreseeing no new irrigation expansions forMurcia, just enhancements of existing ones (MAPA,2002), and consequently water transferred from theEbro is in theory to cover the environmental deficit inthe basin. However, coastal tourism and recreation haveappeared as alternative development options for theRegion (MINHAC, 2000). Announcing the farm/tour-ism conflict over water already apparent in the nearbyMarina Baixa district (Mata-Porras, 2000), many inthe Region (including most interviewed farmers) aresuspicious of the real destination of transferred waterresources.

Perceptions of desertification

The stakeholders’ responses, which sometimes mixconcepts and causes, clearly reflect the ambiguity andbroad scope of the term, implicit in the vague UNCCD(1994, p. 4) definition of desertification: ‘‘Land degrada-tion in arid, semiarid and dry sub-humid areas resultingfrom various factors, including climatic variations andhuman activities’’.Most respondents’ perceptions stemmed from the

climatic scarcity of water as the main characteristic ofthe problem. As 5.NAd1 remarked, ‘‘aridity is fre-quently confounded with desertification’’. Emphasis onthe lack of water due to climatic conditions, andconsequent natural loss of vegetation cover, soil erosion,and loss of productivity, was particularly reflected in theresponses from farmers’ organisations representatives(19.OPA2, 20.OPA3, 21.OPA4, 22.OPA5, 23.OPA6). Inaddition, national administrators related to watermanagement (9.NAd5, 10.NAd6) and irrigation plan-ning (8.NAd4), and regional authorities in the agri-culture department (11.RAd1, 12.RAd2, 13.RAd3,15.RAd5), also fully agreed with this perception.Forming the second category, several respondents

emphasised the human causes of desertification. Forthese interviewees climatic aridity is not itself desertifi-cation but a characteristic condition of semi-aridenvironments. Instead, these respondents (5.NAd1,16.RAd6, 17.RAd7, 25.NGO2) pointed to the influencesof human activities as the main component of deserti-fication, mainly deforestation and inadequate agricul-tural practices.

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ARTICLE IN PRESSJ.J. Onate, B. Peco / Land Use Policy 22 (2005) 103–114 107

Desertification understood as humans deserting thearea, agricultural abandonment and/or populationloss following fall of land productivity, forms a thirdcategory of the problem perception among the respon-dents (8.NAd4, 14.RAd4, 18.OPA1, 23.OPA6, 26.PC1).The drivers of this fall in land productivity were seen tobe both aridity and market conditions, and the problemwas invariably located in the nowadays economicallynon-profitable dry lands. As respondent 18.OPA1 putit ‘‘if there is no farmer activity, desertificationincreases’’.A fourth category of respondents stressed the need to

actualise the concept of desertification in order to focusattention on the unsustainable management of waterresources, which they regard as the main component ofactual desertification processes. Overgrazing, deforesta-tion and inadequate agricultural practices were allconsidered causes of past erosion in the hills. Instead,these respondents (2.Ac2, 24.NGO1) identified irra-tional overexploitation of aquifers, due to irrigationexpansion, as the main driving force of the currenterosion and salinisation problems. Respondent 2.Ac2pointed out the difficulty of recognising problems,which, like desertification, are based on value judge-ments: ‘‘loss of productivity accompanies desertificationfor those interested in biological production (fixedcarbon/m2), but from the economic point of view evena degraded soil may be quite profitable if inputs ofmatter and energy are provided’’.Finally, a fifth category understood desertification as

a global process of environmental degradation, withboth natural and human drivers, and multiple spatialexpressions, ‘‘resulting from the rupture of the equi-librium between natural resources and socio-economicsystems’’ as respondent 3.Ac3 expressed it. Academics(1.Ac1, 3.Ac3, 4.Ac4) and two national administrators(6.NAd2, 7.NAd3) supported this view. Relationshipsbetween in-migrant workforce and natural residents andtheir role in development were considered as well ascontemporary expressions of the global process byrespondent 1.Ac1.

3The lack of consideration for the environmental dimensions of

water completes the axes of the so-called ‘water paradigm’ (Saur!ı and

Del Moral, 2001), which has determined Spanish water policy ever

since.

Historical trends of land use change in the area

Historical trends and social and technological changeaffecting the entire Region emerged in the research asthe framework for an understanding of contemporaryland use changes in the Guadalent!ın.Millenary irrigation cultures existed along the lower

river courses, typically limited by technological factors.The remaining territory was only densely occupied in the18th century, when dry land agriculture expanded intothe uplands, causing serious soil erosion and sporadicflood damage in the main lowland cities (Romero-D!ıazet al., 2002). But the late 19th century railway link

between Murcia and the inner Peninsula facilitated thearrival of much more competitive cereal from Castile,triggering an impoverishment of the regional economyand emigration. By that time, ‘Murcia and its farmerswere amongst the poorest in the country’ (4.Ac4).Irrigation promotion entered the political arena at the

turn of the 20th century, when water become aninstrument of social, economic and spatial transforma-tion and the state paid for the costs of the necessarydams and related infrastructure.3 Opportunities arosefor individual farmers and job-creating agro-businesscompanies, reversing the emigration trends (S!anchezand Ort!ı, 1993), and under the model of the Develop-ment Plans of the 1960s (Harrison, 1993), ‘the south-eastof the Peninsula was definitely allotted the function ofhorticulture and fruit production’ (1.Ac1). Conse-quently, water demands for irrigation increased andthe arrival of submersible pumps initiated the ‘mining ofgroundwater resources’ (5.NAd1).The ‘off-site implications of the new model’ (7.NAd3)

became evident with the construction of the Tagus–Segura transfer channel in the mid-1970s. The channelbrought water from the centre of the country, con-tributing to the expansion of both real and perceivedwater availability. Land was ploughed above thedesignated transfer height (200m), following the reason-ing ‘we’ll first plough and then we will be given water’(3.Ac3). However, an intense drought in the late 1970srevealed that the design parameters for the channel hadset unrealistic expectations of water surplus in the donorbasin (L !opez-Berm !udez et al., 2002). As a consequence,Murcia never received the expected yearly 900Hm3 ofwater, and the water deficit become structural in thebasin (CHS, 2001).As of the dry lands, the highest erosion rates were

probably reached in the 1940s, when cereal growing waspromoted even at the expense of forest areas (Barber!aet al., 1997). Further changes continued in the 1960swhen the esparto (Stipa tenacissima, a native grassspecies used traditionally in wickerwork) became uselesswith the appearance of plastic. Almonds, carobs and figswere planted in esparto areas, many slopes ploughedvertically when tractors became available. Severe floodsand their effects on lowland settlements made thesituation worse and preventive forestation measureswere implemented in the uplands during the 1950s.Aggressive methods such as terracing with heavymachinery and conifer plantations were widely intro-duced, clearly out of place in most cases (Chaparro andEsteve, 1995): ‘Those policies mostly worsened many ofthe existent problems’ (5.NAd1).

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Decline of dry land crops and orchards and expansionof horticulture and fruit growing were exacerbated bynew market opportunities for irrigation products after1970. The preferential agreement with the EEC facilitatedaccess to and demand from the international market,which opened completely on Spain’s accession in 1986and the Single Market in 1992 (P!erez Yruela, 1995).4 Asone respondent argued, ‘business dynamics in agricultureran ahead of the process’ (4.Ac4), and not surprisingly,government support for irrigation increased in the formof infrastructure construction and farm subsidies. Atten-tion was diverted away from dry lands and cerealsdeclined further with the late 1970s drought. Theconsequent abandonment of traditional soil conservationtechniques accelerated the ongoing erosion problems(Cerd!a, 1997), although in some areas a slow butconstant process of shrub vegetation recovery was alsoreported (Obando, 2002). Logically, the water deficit inthe basin has also kept increasing (CHS, 2001),5 despitepart of each new water input being theoretically allocatedto deficit avoidance. Irrigation technology has beengeared to serve this expansion, since ‘every drop of savedwater is used in subsequent irrigation expansion andyields increased productivity’ (24.NGO1).As a result, in less than two generations farmers have

returned from forced emigration to industrial centres inBarcelona and Madrid to live in the region with one ofthe highest growth rates of agricultural productivity inthe country (CESRM, 1997). This clear enhancementof people’s economic standards has led to a socialmomentum in favour of irrigation at the expense of dryland farming. Several interviewees used the Latinexpression, ‘animus regandi’: ‘People irrigate because itis part of their culture’ (9.NAd5). Further, irrigation hasrecently acquired surprising functions in peoples’perceptions based on the assumed equations of water=irrigation, drought=desertification: ‘Irrigation is aconstraint on the advance of the desert’ (20.OPA3) or‘In this Region they say that the desert begins wherelettuces end’ (9.NAd5).

Contemporary policies and ultimate effects—the policy

impacts

Irrigation expansion

Early policies underlying irrigation expansion culmi-nated in the construction of the Tagus–Segura transfer

4Volume of vegetable exports doubled between 1986 and 1996,

representing in the latter 47.5% of the entire Murcian foreign trade

(INE, 2000), Germany, the United Kingdom, France and The

Netherlands being the destination of 84% of horticulture foreign

trade (CESRM, 1997).5 ‘It is now officially estimated to be 460Hm3, although considering

illegal overexploitation, it may reach 800Hm3’ (9.NAd4).

channel in the late 1970s (CHS, 2001), when mostpermits for running water were also allocated. Sincedemand by the transformed areas exceeded the wateractually transferred, ‘Groundwater extractions werebegun provisionally (for 2 years) in expectation offurther transfers that did not arrive’ (8.NAd4). Constantgroundwater exploitation began, and enhanced techno-logy enabled wells to be drilled deeper.The 1985 Water Act legalised most groundwater

pumps and instituted a permit system, but could notinhibit their illegal spread: ‘The Water Act reachedMurcia 20 years too late, when most wells were alreadyoperating’ (12.RAd2). As irrigation business grew, anunregulated water market arose, with permit ownersillegally selling part of the water they were allocated butdid not use. ‘The mobility of water all across the Regionhinders control over its legal origin, and the CHS justsits and watches what happens’ (24.NGO1).After Spain’s entry into the EEC, structural aid for farm

modernisation (under Regulations EEC/797/85, EEC/2328/91, EC/950/97, EC/1257/99) promoted increasedproductivity and indirectly, irrigation expansion. Nowwith full powers in agriculture and environment, ‘TheRegion defended its farmers by consolidating irrigationjust to worsen the deficit and force new water transfers’(8.NAd4). Regional administrators argue that they wereonly pursuing water use efficiency but ‘did not have powerover water management’ (13.RAd3). CHS respondentscomplain that they did not have enough staff to cope withthe Water Act provisions, which ‘was an excessiveresponsibility for this body’ (9.NAd5). Academics believethat, ‘Delegation of responsibility by CHS to other actorsis an historic phenomenon: they did let it happen’ (2.Ac2).Conversely, EU accession did not serve to limit or controlirrigation expansion since the Common AgriculturalPolicy (CAP) has never covered horticulture production.Farmers’ vision, in turn, still demands more support

to irrigation agriculture from public authorities, par-ticularly for small and medium sized holdings. Whensurface waters became scarce and in order to affordinvestments made to introduce irrigation, they ‘wereobliged to extract groundwater’ (20.OPA3), and ‘thanksto that we have survived’ (19.OPA2). They complainthat the regional agriculture administration and theCHS have not co-ordinated efforts in order to managethe dynamics of irrigation expansion, and that they havefavoured big companies of industrial agribusiness to theneglect of the small farmer: ‘Big producers are the oneswho really control the situation: water, market, invest-ments’ (18.OPA1). Anyhow, irrigation is seen as theonly development possibility for them, so they keep ondemanding water, although some of them recognise that‘the legacy to our children is going to be a disaster’(23.OPA6).The 1999 Water Act prohibited new wells but

could not reverse the trend. As in the rest of Spain

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(Sumpsi, 2001), rural policy design and implementation(e.g. Reg. 1257/99/EEC) is still dominated by a‘productivist’ ethos, in which ‘Agriculture and waterpolicies are combined to modernise and improve thecompetitiveness of irrigation’ (11.RAd1).All respondents agree that aquifer overexploitation is

an effect of irrigation (see also L !opez-Berm !udez et al.,2002; and Lemon et al., 1994 reporting the same effect inthe Greek Argolid), but legally prescribed restorationplans have not been put into practice ‘due to lack ofcollaboration from users’ (10.NAd6). Irrigation withextracted saline water is lowering production due to soilsalinisation in many places (P!erez-Sirvent et al., 2003),especially in the Guadalent!ın, where ‘The situation hasreached a limit in fruit orchards’ (20.OPA3).Water table depletion has dried up natural wells and

wetlands, also widely acknowledged although someargued that ‘The drying of natural wells is due to thelack of rainfall; if it rained they would recover’(16.RAd6). Impact on valuable fauna and flora hasbeen evident in the case of the Saladares del Guadalent!ın

wetland, where ‘Water used to rise to the surface, butthey are now dry and partially ploughed in spite of beinga protected area’ (15.RAd5).Another symptom of water overexploitation has been

the lowering of river flow rates and the inability to dilutesewage from the growing population.6 As newspapersstate, ‘The Segura River is a sewer’ (El Pa!ıs, 1999). Inspite of being responsible for sewage control and watertreatment, the Region has only recently started to tacklethe problem, and ‘Works cannot be finished overnight’(11.RAd1).Besides expansion, specialisation and intensification of

irrigated agriculture have undeniably taken place in thearea,7 with associated land degradation effects such asdiffuse pollution. However, provisions under the NitrateDirective (676/91/EEC) have not been implemented(Izcara Palacios, 1998): ‘To live is to pollute and withan intensive activity like irrigation it is obvious that youmust enter into conflict with the environment’ (14.RAd4).

Changes in dry land areas

In the early 1980s, and with CAP subsidies in mind(e.g. EEC Reg. 2727/75, 466/82 and 797/85), surviving

6According to the 2001 census, regional population has increased

25.03% since 1981, more than three-fold the national figure of 8.21%

(INE, 2002).7 Intensification is reflected in the 1993 figures for the quotient

between Standard Gross Margin and Utilised Agricultural Area, which

was 944.2 h/ha, and for that between Gross Margin and Annual

Labour Unit, which was 11,133h/ALU, two-fold and three-fold,

respectively, the national figures (CESRM, 1997). Horticulture and

fruit growing represented, in the same year, 62% of the total

agricultural production of the region, reflecting a much higher

specialisation than in the rest of the country (28%, CESRM, 1997).

cereal crops as well as traditional almond plantationswere extended at the expense of recovering scrublands,without conservation practices or soil care. ‘Given thepublic and indirect benefits the government should haveresolved the situation by taking the Mediterraneanforest domain out of private hands,’ (5.NAd1). After1986, the CAP clearly helped to expand and intensifydry land agriculture in the hills, with renewed plough-ing-up of abandoned zones, ‘A forbidden but almostimpossible to control practice; no one in Europe hascontrolled it’ (13.RAd3).Following the area payments for cereals, almond

subsidies (e.g. Reg. EEC/1035/72 and EC/2000/96) wereparticularly harmful for erosion (van Wesemael et al.,2003), with new orchards planted after surface levellingwith machinery. Agriculture administrators now ac-knowledge the negative effects of destroying terracingbut, ‘Agricultural policies and thus the governmentfocused exclusively on profitability. The environmentwas scarcely mentioned in the CAP until Agenda 2000’(13.RAd3).Positive effects of CAP regulations were also men-

tioned in the interviews, particularly concerning set-aside (Reg. EEC/1094/88), which in some locations‘facilitate the natural recovery of protective vegetationand reduce previous erosion’ (16.RAd6). Nevertheless,set-aside was also claimed to have been a driver oferosion, especially in places where farmers were stillundertaking soil protection techniques. ‘The Govern-ment should be more careful in selecting areas toimplement these policies’ (3.Ac3).In any case, the extent of current erosion problems

caused by dry land agriculture appears to be muchsmaller than those caused by the uncontrolled irrigatedinvasion of hilly areas (Barber!a et al., 1997). Thanks tothe technical mobility of water, ‘Many farmers who ownboth irrigated and dry land just move their irrigation toless exhausted or salty soils’ (12.RAd2). Further, agri-business companies have bought low-priced dry land,invested in pumping their water allocations, eliminatederosion-preventing structures such as terraces, andinstalled irrigated groves, ‘Greenhouses having evenbeen seen in the mountains’ (13.RAd3). Heavy machi-nery can easily work the highly mouldable metamorphicand sedimentary rock to create a levelled surface which,despite the lack of soil, has enough fine particles to feedthe crop, ‘Agriculture is no longer linked to soil, whichjust acts as a physical base’ (9.NAd5). After the watersupply ends or the soils become too salty for horticul-ture, the transformed plots are usually either re-converted into dry land or directly abandoned. As aresult of the loss of soil conservation techniques, ‘Theerosion hazard may become even greater than before thechanges’ (13.RAd3).Lastly, perhaps the most far-reaching effects of

irrigation expansion in the area, at least in human

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terms, have been on social awareness and culture in thedry lands. In this sense, human, technical and economi-cal resources focussing on the problems and demandsof dry land areas have been kept to a minimum incomparison to those targeting irrigation. As oneagriculture official put it, ‘Contact with dry land farmersis minimal, and is only done to monitor the receivedsubsidies’ (15.RAd5). CAP and the EU were criticisedfor not being sensitive enough to the problems ofsouthern European countries, as ‘These problems arenot understood by those who have not suffered fromthem’ (12.RAd2). As a result, locals have seen how thelegacy of their ancestors has become undervalued ineconomic terms and government consideration, and inthe absence of social recognition, ‘Frustrated farmerstend to refuse the role of ‘nature guardians’ foreseen inCAP reform orientations’ (4.NAd4). In this situation,farmers’ management decisions tend to be more drastic,seeking the most rewarding subsidy regardless of goodagricultural practices, before being forced to abandonthe farm. ‘From a desertification perspective, socialchange operates in a negative way for dry land farmersand their successors’ (2.Ac2).

The role of recent policy instruments

Agri-environmental and agri-forestry schemes

The first agri-environmental programme (Reg. EEC/2078/92) in Murcia (1994–1999) covered nearly 1550farmers (2.7% of total), 40,000 ha (9.1% of arable area)and roughly h 8.97 million. Unfortunately, a breakdownof figures for the Guadalent!ın area is not available.As in many areas of Spain (Peco et al., 2000), the

Regional Agriculture Department blamed the limitedimplementation of this scheme on budget restrictions,especially since in Murcia, ‘Irrigation is a top priorityand agri-environmental measures have more budgetarylimits’ (11.RAd1). Passive resistance against the agri-environmental schemes was also related to the conflictthey face with predominant ‘productivist’ orientations(Peco et al., 2000) and its high transaction costs, ‘whichcaused the delay and low level of its implementation’(7.NAd3). Although these initiatives were considereduseful for avoiding erosion and reducing agro-chemicalusage, many respondents claimed the present CAP doesnot adequately support them, ‘Payments from theseinitiatives are quite low’ (19.OPA2).The cereal extensification measure has been the most

important in terms of uptake, particularly in the upperpart of the basin where around 4000 ha are engaged inthe programme, ‘Ploughing along contour-lines is themost rewarding commitment in terms of erosionprevention’ (13.RAd3). The measure for integrated pestcontrol on white grape vineyards has also been

important, concentrating most education and trainingefforts. However, its anti-desertification role seemslimited because it is implemented on irrigated land,and the lack of a national regulation on integratedproduction ‘facilitates the concealment of commercialproduction under an environmental facade’ (7.NAd3),an opinion shared by environmentalist groups. Nofigures on the uptake of organic farming were available,but since no detailed requirements concerning goodagricultural practices were included in the measure, itsimpact on desertification is doubtful beyond the positiveeffects of lower chemical usage.A new agri-environmental programme is available for

the 2002–2006 period, including measures for dry landerosion combat, cereal extensification, organic farming,integrated pest control and education and training. Thenumber of applications (approximately 5000 farmers)has surpassed expectations and all measures include acompulsory code of good agricultural practice. Theprogramme design, particularly the integrated controlmeasure, was nevertheless thought to have insufficientdetails since, ‘The technical complexity of these issues isnot appropriately reflected in the commitments becausethe government lacks sufficient technical support’(13.RAd3). For academics, anti-desertification measuresshould be targeted much more at specific areas, giventhe spatial diversification of existing problems andopportunities (L !opez-Berm !udez et al., 1997), ‘a matterof sensitivity and technical capacity’ (2.Ac2).The agri-forestry scheme (Reg. EEC/2080/92) suf-

fered from scarce budget allocation even in comparisonto the agri-environmental package, in spite of theperception that it is ‘highly positive in terms of retiringlow-productive, intermittently cultivated dry lands and acommon source of desertification’ (12.RAd2). Onlyapproximately 10,000 ha have been planted in the entireRegion (Guadalent!ın data unavailable). Nevertheless,this scheme was also criticised because of designdeficiencies, ‘It just promotes tree plantations with aview to productivity, which is ridiculous in a semiaridclimate’ (24.NGO1). Furthermore, ‘It is creating amosaic of unconnected forested patches with a dubiousenvironmental outcome’ (7.NAd3).Altogether, the so-called ‘subsidy culture’ was raised

as a threat concerning desertification, especially in thecase of the foreseen reduction or even completeabandonment of the subsidy regime by 2006–2008,‘farmers accustomed to subsidies might abandon soilconservation practices, which for better or worse, theyare performing today’ (3.Ac3). This is a visionunfortunately confirmed by one respondent from afarmers’ organisation: ‘they go into these schemesbecause it helps in monetary terms not so much becauseof principles’ (19.OPA2).Modulation or cross-compliance of direct payments

were seen as possible financial sources to overcome the

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budgetary restrictions on these schemes. However, itsapplicability in Murcia was said to be low, ‘becausethere are not that many big holdings’ (13.RAd3) and‘due to lack of political will’ (7.NAd3).

Hydrological corrective measures and forestry measures

As in the rest of Spain, these have been the onlypublicly financed erosion initiatives, with two types ofinstruments usually implemented on public land (RojoSerrano, 1998). First, water authorities design andexecute projects for the hydrological correction ofcreeks and protective forestation in order to preventdams filling with sediments. Second, forest servicesimplement forestation measures, under ‘protective’ or‘productive’ aim depending of the location. Both havebenefited from the EAGGF-Section Guidance and theCohesion Funds after accession to the EU.Methods and techniques have been criticised regard-

less of the instrument and the Government concerned(e.g. Garc!ıa P!erez and Groome, 2000), as the quantity ofthe forested area rather than quality of the restoredecosystem is usually the main objective. The Guada-lent!ın is not an exception, and examples of counter-productive actions (e.g. aggressive terracing methods,planting of inadequate species and lack of site-targeteddesign) abound, since ‘A standard model has beenimplemented regardless of site-specific conditions’(4.Ac4). In spite of the general experience, examples ofgood erosion control results were also mentioned, andcommunity memory of flood damage in the areaexplains why locals generally perceive these measuresas having positive effects on desertification. There hasbeen no official systematic monitoring of their effects onerosion rates, and the number of afforested hectares isthe only indicator of effectiveness (Chaparro, 1994).More interest was expressed in bolstering instruments

to subsidise measures in private forests (58% of regionalwooded surface, CAAMA, 2001), since ‘due to lowproductivity owners do not take care of forests, leadingto a greater fire hazard’ (16.RAd6). Although instru-ments serving these ends have been in place for a longtime (e.g. Reg. EEC/1610/89) and they are considered tobe ‘Adequate tools to fight desertification’ (6.NAd2),budget cuts have prevented their wider implementation,‘Forestation of marginal or abandoned agriculturalland, managed by the Agriculture Department hastaken the lion’s share’ (16.RAd6).

Land use planning and related policies

Paradoxically, the expansion of intensive irrigationis forbidden since 1986, when the first Regional landuse planning legislation was issued. Subsequent hydro-logical planning documents confirm this limitation.In reality, however, it seems obvious that ‘Physical

planning has been subsumed to the logic of irrigationexpansion’ (1.Ac1). Many respondents doubt whetherthese policies could have stopped or re-oriented irriga-tion expansion: ‘There is no way to resist such powerfulsocial and economic pressure’ (17.RAd7, 2.Ac2).In Spain, land use planning policies have traditionally

focused exclusively on the territorial location ofeconomic activity and necessary infrastructure arrange-ments (Onate et al., 2002a). This approach partlyexplains why the total area of protected land in theRegion was reduced by near 11,000 ha in 2001, mainlyaround areas of agricultural and/or tourist interest (LaOpini !on, 2001). Related legislation on nature conserva-tion, for example, has not prevented the perfectly visibleinvasion of protected areas by expanding irrigation, aprocess denied by respondents from the RegionalGovernment, ‘Non-agrarian zones have not beenaffected’ (16.RAD6), belittled, ‘Invasions are not overallsignificant’ (12.RAd2), or justified, ‘Levelling is abenefit, not an erosion problem because it compactsthe soil’ (15.RAd5). Although planning documents(MIMAM, 2001a; CHS, 2001; MAPA, 2002) mentionthe need to take environmental considerations intoaccount when implementing irrigation projects, experi-ence shows that this has never been a priority. ‘Impactmitigation measures should have been implementedbefore, to preserve particular locations of outstandingnatural interest, avoiding landscape simplification, andmaintain native vegetation strips to enhance connecti-vity between natural habitats’ (2.Ac2). In the absence oflegislation prescribing environmental assessment at thestrategic levels of plans or programmes (Onate et al.,2002b), impact assessment at the project level hasproved unable to control irrigation expansion andameliorate its subsequent effects, ‘in spite of legislationthat prescribes it for every transformation’ (25.PC1).Unfortunately, in February 2004 Spain is the only

northern Mediterranean country that has not deliveredto the UNCCD its National Action Plan to CombatDesertification (NAPCD), and only a working draft wasmade available in 2001 (MIMAM, 2001b). Significantlyonly seven out of the 25 interviewees acknowledgedfamiliarity with the draft NAPCD, eight had heardabout it but were not aware of details, while theremaining 10 were unaware of its existence. In the lightof this poor result at the local level, it seems fullyjustified the appreciation that its design process, ‘lackscommunication with society, and many GovernmentDepartments disown the plan’, as one of its writersrecognised (3.Ac3). However, it is significant that therespondents from the CHS, the Physical PlanningDepartment and four of the representatives of farmers’organisations were not aware of the NAPCD.The fact that the Plan is co-ordinated nationally by

the Ministry of Environment could explain the lowinterest detected amongst agriculture-related actors.

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Further, its coincidence with the passage of othernational plans related to the issue such as the Hydro-logical and Irrigation Plans, was pointed out as evidenceof the lack of political will to tackle the root of theproblem. ‘Governments attach much more importanceto other issues, while desertification is politicallyunprofitable’ (6.NAd2).

Conclusions

The stakeholder interviews in the Guadalent!ın basinillustrated the clear impacts of past policies on landdegradation, reflecting that desertification, as an envi-ronmental issue, has suffered from the so-called‘Mediterranean syndrome’ (e.g. La Spina and Sciortino,1993), which makes the promotion of non-economicinterests rare or at least difficult at a local level. Thedifferent dynamics followed in irrigated and dry landareas require a separate re-orientation of anti-desertifi-cation policies in each area.Current social, economic and institutional attention is

clearly focussed on the new prospects of water transferforeseen in the recently passed NHP. Experts haveargued that solutions to the structural water deficit inthe basin have been tackled from the supply side ratherthan from the demand side (e.g. Sumpsi et al., 1998).Although no new expansions of the irrigated area areofficially foreseen for the Region, further irrigationexpansion can be expected due to economic reasons.Considering that the marginal value of water allocatedto conversion of dry land into irrigation is at least threetimes that of water allocated to precarious irrigationconsolidation,8 the most rational economic behaviourby farmers is to further expand their irrigated land.Therefore, established control mechanisms in the NHPto police the destination of transferred water are in riskto be as useless as those included in previous regulations.Even the full implementation of the EU Water

Framework Directive, which establishes the integralrecovery of investment and maintenance costs of newinfrastructures, does not seem capable of deterring thisunsustainable expansion (Escart!ın and Santaf!e, 2001).The marginal productivity of water for this type ofintensive irrigation is 0.3–0.6 h/m3, and even higher ingreenhouse farming (MAPA, 2002), still enough tocompensate for the future cost of transferred NHPwater, estimated to be roughly 0.31 h/m3. Even if thelarge transfer infrastructure envisaged in the NHPwere not built,9 irrigation expansion has the potential

8According to figures from the own NHP, estimations for the

marginal value of water range between 0.18–0.36h/m3 in the former

case and 0.054 h/m3 in the latter (MIMAM, 2001a).9This is a plausible possibility due to the protests against the transfer

in donor regions and to the doubts about EU co-financing (total cost is

estimated at present at more than 4 billion h).

to continue. Desalinated seawater currently costsaround 0.42–0.48 h/m3, but future technological devel-opments will probably lower this to figures perfectlyaffordable by intensive irrigation farmers (Sumpsi et al.,1998).Therefore, neither water prices, which in this case do

not serve to regulate water demand, nor CAP regulations,which do not cover this type of production, will be able tocontrol irrigation expansion. In policy terms, only strictenvironmental policy enforcement to tackle the negativeon- and off-site impact can bring the situation undercontrol, although the economic and political costs of thisoption will clearly be high. The only other restraint towater demand and irrigation expansion comes from themarket side. Although only foreseeable in the longer termin the context of further international trade liberalisation,a possible saturation of European fresh vegetable andfruits markets could be expected following increasedimports from third countries (e.g. Morocco).The possibility of addressing desertification in dry land

areas through policies seems much more feasible, simplybecause expectations of economic results are much lowerthan on irrigated land. Current policies, mainly EU driven,have played a contradictory two-fold role, simultaneouslypromoting agricultural set-aside and land use intensifica-tion, while erosion mitigation has never been an objectiveof the agricultural subsidies. However, clearer options tofocus policies on desertification are now starting to appearat present. The new agri-environmental schemes begun in2002 are the closest positive example. In addition, publicforest management schemes and forestry measures onprivate land could be implemented in the near future underthe recent Regional Forest Strategy. Most importantly, themedium-term CAP review could free more budgetresources to empower these socially and institutionallyfeasible options.

Acknowledgements

The European Commission funded this work under theongoing research project MedAction: Policies for landuse to combat desertification (EVK2-CT-2000-00085).More information is available at www.icis.unimaas.nl/medaction. Thanks go also to C. Cummings, A. G!omezand J. Sumpsi who collaborated in the first stages of thisresearch, to all those who participated in the interviews,and to three anonymous reviewers whose commentsgreatly improved previous versions of the paper.

Appendix A. Stakeholder identification

The 25 interviewed stakeholders are classified into thefollowing six groups, showing the background and

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position of each stakeholder:

* Academics (Ac):

1.Ac1. Sociologist. University of Murcia.2.Ac2. Biologist. Researcher at CSIC-CEBAS.3.Ac3. Geographer. Murcia University.4.Ac4. Economist. Researcher at CSIC-CEBAS.

* National administration (NAd):

5.NAd1. Forest Engineer. Environmental En-gineering Area, Public Works Ministry.6.NAd2. Forest Engineer. Co-ordination Officeof NAPCD, Environment Ministry.7.NAd3. Agronomist. Agri-environmentalSchemes Area, Agriculture Ministry.8.NAd4. Agronomist. Co-ordination Office ofthe National Irrigation Plan, AgricultureMinistry.9.NAd5. Civil Engineer. Water Authority, En-vironment Ministry.10.NAd6. Civil Engineer. Water Authority,Environment Ministry.

* Regional administration (RAd):

11.RAd1. Lawyer. Regional Agriculture,Water and Environment Department advisor(CAAMA).12.RAd2. Agronomist. Irrigation InfrastructureService, CAAMA.13.RAd3. Veterinary surgeon. Technical Sup-port Service, CAAMA.14.RAd4. Agronomist. Water Planning Service,CAAMA.15.RAd5. Agronomist. Guadalent!ın AgrarianOffice, CAAMA.16.RAd6. Forestry Engineer. Natural ResourcesService, CAAMA.17.RAd7. Civil Engineer. Regional PublicWorks and Physical Planning Department.

* Professional Agricultural Organisations (OPA):

18.OPA1. Agronomist. COAG farmers’ union,Murcia.19.OPA2. COAG Secretary, Lorca.20.OPA3. Pantano de la Cierva IrrigationFarmers’ Union.21.OPA4. Totana irrigation-farmers’ association.22.OPA5. Agronomic Technical Engineer. Lorcairrigation-farmers’ association.23.OPA6. President of AGROSOL co-operative.

* Non-Governmental Organisations (NGO):

24. NGO1. Biologist, Ph.D. EnvironmentalistGroup Ecologistas en Acci !on-Murcia.

* Private Environmental Consultants (PC):

25.PC1. Biologist. Ambiental Ltd.

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